Massachusetts Court Upholds Sun Life’s ERISA Disability Denial Under the Deferential Abuse-of-Discretion Standard

In Sargent v. Sun Life Assurance Company of Canada, No. 24-11500-BEM, 2026 WL 1506531 (D. Mass. May 29, 2026), the United States District Court for the District of Massachusetts granted summary judgment to Sun Life and denied the claimant’s cross-motion, upholding the termination of long-term disability (“LTD”) benefits under ERISA’s deferential abuse-of-discretion standard of review.

Why did the court apply the abuse-of-discretion standard instead of reviewing the denial de novo?

Plaintiff stopped working in December 2018 due to pain, fatigue, lack of endurance, and cognitive limitations stemming from a non-work-related shoulder injury, later associated with diagnoses including fibromyalgia, bilateral occipital neuralgia, cervical degenerative disc disease, and trigeminal neuralgia. Sun Life approved LTD benefits effective July 2019. After the policy’s definition of disability narrowed at the twenty-four-month mark, from an inability to perform the claimant’s own occupation to an inability to perform “with reasonable continuity any Gainful Occupation,” Sun Life terminated benefits effective September 30, 2022, and upheld that decision on appeal in April 2024.

The court first determined the applicable standard of review. Because the Plan stated that Sun Life “has discretionary authority to make all final determinations regarding claims for benefits,” including the right to determine eligibility and construe the policy’s terms, the court found this language unambiguously conferred discretion. Applying Firestone Tire & Rubber Co. v. Bruch, the court reviewed the denial for abuse of discretion, a standard it described as “generous” and one under which a decision must be upheld if there is “any reasonable basis for it.”

Did Sun Life apply the wrong disability standard by saying Plaintiff could work “full time”?

Plaintiff argued that Sun Life failed to apply the “reasonable continuity” component of the Gainful Occupation definition, pointing to communications in which Sun Life did not use that exact phrase. The court rejected this argument. It noted that at least one of the cited communications contained no benefits determination at all, and that Sun Life’s reviewing physicians’ conclusions that Plaintiff could “sustain working full time including 8 hour days, 40 hours a week” did not signal application of the wrong standard. The court further observed that both the initial and final determinations expressly quoted the “reasonable continuity” provision. The failure to repeat the phrase throughout the correspondence did not establish that Sun Life applied an incorrect standard.

How much weight did the structural conflict of interest receive?

The parties agreed a structural conflict existed because Sun Life both evaluates and pays claims. The court explained that such a conflict does not change the standard of review but may be given extra weight in certain circumstances, with the claimant bearing the burden of showing the conflict influenced the decision. Finding that Plaintiff had not demonstrated actual influence, and that Sun Life had taken steps to insulate its process, including using independent physicians, a separate appeals unit, and good-faith payments under a reservation of rights, the court afforded the conflict little weight.

Did Sun Life give Plaintiff a sufficient explanation and a fair opportunity to respond?

Plaintiff argued the final determination failed to provide an adequate explanation under 29 U.S.C. § 1133 and denied her the opportunity to review and respond to evidence. The court declined to view the final determination in isolation, reading it together with the initial determination and prior correspondence. Across those communications, Sun Life had identified the claim history, relevant policy terms, the evidence considered, and the competing physician opinions. The court found the twenty-two-page final determination, alongside a record exceeding 6,500 pages, satisfied the statute. On the opportunity-to-respond issue, the court found Plaintiff had received the reports of Sun Life’s reviewing physicians and had in fact responded to them, and that she identified no new factual information or argument she was prevented from submitting. Citing Metzger v. UNUM Life Insurance Co., the court noted that requiring response to reports containing no new factual information would create an endless cycle of submission and review.

Was it reasonable for Sun Life to credit its own reviewers over Plaintiff’s treating physicians?

The court held that Sun Life’s decision was supported by substantial evidence. Under Black & Decker Disability Plan v. Nord, administrators are not required to give special deference to treating physicians, and the existence of contrary medical evidence does not by itself render a decision arbitrary and capricious. The court found it was not unreasonable for Sun Life to credit opinions grounded in physical examination findings and objective evidence over opinions resting primarily on Plaintiff’s subjective symptom reports. It pointed to examination findings of normal motor strength, normal sensation, and normal gait, concluding that the objective record did not corroborate the extreme level of pain and limitation Plaintiff described.

What about Plaintiff’s Social Security disability award?

Plaintiff argued Sun Life failed to credit the SSA’s award of disability benefits. The court reiterated that SSA determinations are not binding on disability insurers and held that Sun Life adequately explained its disagreement: the SSA’s eligibility review predated the period relevant to the Plan determination, the SSA applied different criteria than the Group Policy, and Sun Life relied on updated treatment records and physician opinions unavailable to the SSA. The court found this explanation sufficient under the governing regulations.

Concluding that Sun Life had substantial evidentiary grounds for a reasonable decision, the court granted Sun Life’s motion for summary judgment and denied Plaintiff’s.